The NMA has filed comments on the Environmental Protection Agency’s (EPA) proposal creating national mercury emission standards for a gold mine ore processing and production area source category, which falls in the hazardous air pollutant section of the Clean Air Act (CAA). The Nevada Mining Association, NMA and several member companies that own and operate gold ore processing and production facilities developed comprehensive comments on the EPA proposal.

Firstly the NMA found that the agency did not adequately justify a basis for listing gold mining as a source category under section 112 (C) (6) of the CAA, while highlighting that Nevada is already implementing an effective mercury control program – that the EPA previously agreed satisfies the need for a federal program. The NMA also pointed out that existing sources of emissions should have three years to comply with Maximum Achievable Control Technology (MACT) standards, rather than the two years proposed. The NMA feels that since little, if any, benefit would be realised in terms of improved compliance with MACT standards the EPA should exclude gold mine ore processing and production area sources from Title V requirements.

Summing up the EPA’s proposal the NMA commented that it would be inappropriate and unnecessary for the EPA to include certification or management practices for hydrogen cyanide emissions in a rule developed to address mercury emissions.